Corporation has US real property interest and the shares of the corporation are owned by a foreign shareholder. The US real property interest is disposed of months before the corporation makes a liquidating distribution. My understanding is that since the assets were disposed of and gains were taxed FIRPTA withholding requirements should not apply. Further since the liquidating distribution resulted in capital gains (no E&P) the capital gain would be exempt from US taxation because the relevant treaty exempts capital gains. Any thoughts or comments will be appreciated.